Secretary Kathleen Sebelius
Department of Health and Human Services
Division of Global Migration and Quarantine
Centers for Disease Control and Prevention
Attn: Part 34 NPRM Comments
1600 Clifton Road, NE., MS E-03
Atlanta, GA 30333
Re. Docket No. CDC-2008-0001
Dear Secretary Sebelius:
We write as religious institutions and faith-based organizations with extensive experience in the response to HIV and AIDS throughout the world. We applaud the Department of Health and Human Services (HHS) proposed rule published in the Federal Register on July 2, 2009, which removes Human Immunodeficiency Virus (HIV) Infection from the definition of communicable diseases of public health significance from Title 42, part 34, of the Code of Federal Regulations.
In July of 2008, during the reauthorization of the President’s Emergency Plan for AIDS Relief (PEPFAR), many of our organizations urged the Senate to restore authority to the U.S. Secretary of HHS to determine the most appropriate entry policy procedures for HIV-infected individuals. Our advocacy efforts in this regard were motivated by the conviction, based on our experience, that the underlying law was outdated, no longer served any important public health interest and actively undermined the leadership provided by the United States in the global response to HIV and AIDS.
We are pleased that the rule proposed by HHS acknowledges that “While HIV infection is a serious health condition, it does not represent a communicable disease that is a significant threat for introduction, transmission, and spread to the United States population through casual contact.” Major U.S. medical and public health organizations (American Medical Association, American Public Health Association, Association of State and Territorial Health Officials, National Association of Country Health Officials, etc.), as well as international health bodies (World Health Organization, Joint United Nations Programme on HIV/AIDS, International Red Cross) concur with the conclusion stated above and maintain that no public health interest is served by policies that restrict HIV-positive people from crossing borders.
As faith communities we respond to God’s love by welcoming the stranger, healing the sick, serving those living in poverty and caring for those in need. The fear that once surrounded the spread of HIV that paralyzed the response of the international community, including many faith organizations, has been replaced by facts. Decades of experience has made it abundantly clear that behavior change, not border control measures, will stop the spread of AIDS.
Informed by our work both domestically and internationally in the fight against AIDS, we believe that eliminating the HIV-specific grounds for inadmissibility to the United States will help reduce stigma and discrimination against HIV-positive persons, enhance U.S. leadership in the global fight against AIDS and allow our ministries to more effectively partner with those most severely affected by HIV and AIDS in the world. Therefore, we support the proposed HHS rule which removes Human Immunodeficiency Virus (HIV) Infection from the definition of communicable diseases of public health significance from Title 42, part 34, of the Code of Federal Regulations and urge you to finalize this rule as soon as possible.
Cameroon Baptist Convention Health Board
Catholic Legal Immigration Network (CLINIC)
Center for Reflection, Education and Action
Church World Service
Ecumenical Advocacy Alliance
The Episcopal Church
Evangelical Lutheran Church in America
Friends Fiduciary Corporation
Lutheran Immigration and Refugee Service
Maryknoll Office for Global Concerns
Mennonite Central Committee U.S. Washington Office
Mercy Investment Program
Office of Justice and Peace Sisters of Charity of New York
Presbyterian Church, (USA), Washington Office
Province of St. Joseph of the Capuchin Order
Sisters of Mercy Regional Community of Detroit Charitable Trust
Ursuline Sisters of Tildonk, U.S. Province
Universal Fellowship of Metropolitan Community Churches
United Methodist Church, General Board of Church & Society
United States Conference of Catholic Bishops